All industrial permits sources were reviewed to insure that appropriate requirements had

been applied and that these requirements constituted RACT. The following are thirteen sources that had the highest sum of emissions of combined NO x , SO 2, and Particulate. Particulate was used because PM 2.5 emission factors are limited. These sources were reviewed to verify

that the sources were subject to RACT levels of controls. Industrial emissions were reviewed to see if there was a possibility of any additional controls that could change the attainment date from the end of 2009 to the end of 2008. No additional controls were found. Table 15 shows that no possible reductions will result in a 2008 attainment.
Brach’s Confections Company Number 0300 Full Compliance Evaluation: April 24 2007. The source was in compliance. Allowable Emissions: Particulate 46.31 tons per year

NO x 41 tons per year SO 2 0.18 tons per year Natural Gas Combustion only This source is subject to the following rules. 1. 40 CFR P art 60 Subpart DC

– Standards of Performance for Small Industrial

– Commercial

- Institutional Steam Generating Units 2. Particulate Rule 10 3. Opacity Rule 3 4. Particulate BACT 4

- 8(e)(2)b Three boilers on site are fired b y natural gas only. One 21. 32 million BTU/hr boiler One 15.7 million BTU/hr boiler One 30.1 million BTU per hour boiler The 15.7 million BTU/hr Boiler is subject to 40CFR Part 60 Subpart Dc
- Standards of Performance for Small Industrial

- Commercial

- Institutional Steam Generating Unit. Process equipment emits 2.5 TPY of particulate at maximum operating rate. Process emissions are controlled by baghouses.2

East Tennessee Natural Gas Company Number 5340 Full Compliance Evaluation March 29, 2007. The source was in compliance Emis sions Particulate is 2.24 tons per year. All particulate is PM2.5.

Allowable NO x 48.20 Tons per year. Subject to the following as adopted into the Chattanooga Air Pollution Control Ordinance 1. 40 CFR Part 60 Subpart GG Standards of Performance for Stationary G as Turbines. 2. Chattanooga Air Pollution Control Ordinance Rule 15 Adoption of NSPS Both turbines burn pipeline natural gas and have been stack tested. The allowable NO x limit in the NSPS is 150 ppm. The older turbine which was tested in 1991 demonstrated NO x emissions of 63 ppm or 3.7 lb/hour. The newer turbine which was tested in 2002 demonstrated NO x emissions of 14.2 ppm or 2.72 lb/hr. If both turbines ran 8760 hours, the potential emissions would be 28.12 tons per ye ar. Fuel sulf ur has also been demonstrates as 0.02 % which is well below the NSPS allowable of 0.08%. Particulate is likely

to be overestimated as discussed in the emission inventory document that said that particulate emissions from combustion of natural gas are significantly overestimated.3

Erlanger Medical Center Company Number 0150 Full Compliance Evaluation completed on October 23, 2007. The source was in compliance Allowable/ Actual Emissions Particulate 11.87 TPY NO x 71.92 TPY SO 2 18.00 TPY S O 2 is limited by

the permit to 500,000 gallons on Number 2 fuel oil with 0.5% sulfur. There are 4 permitted boilers that provide steam for a large medical center. The boilers are fired on natural gas but use Number 2 fuel as a backup fuel. Depending on steam demand one or two boilers will be operated at a time. Though the facility is permitted for Number 2 oil with 0.5% sulfur oil, the facility u sed 3600 gallons and the number 2 oil was 0.1865 % Sulfur in the last year. This source is subject to the following rules.

1.40CFR Part 60 Subpart Dc Small Industrial

- Commercial

- Institutional Steam Generating Units 2. Particulate Rule 27.3 3. Opacity Rule 3 10% Opacity limits 6. SO 2 Rule 13.2 Quarterly Sulfur Reports Required4

Erlanger Medical Center Company Number 0150 Full Compliance Evaluation completed on October 23, 2007. The source was in compliance Allowable/ Actual Emissions Particulate 11.87 TPY NO x 71.92 TPY SO 2 18.00 TPY SO 2 is limited by

the permit to 500,000 gallons on Number 2 fuel oil with 0.5% sulfur. There are 4 permitted boilers that provide steam for a large medical center. The boilers are fired on natural gas but use Number 2 fuel as a backup fuel. Depending on steam demand one or two boilers will be operated at a time. Though the facility is permitted for Number 2 oil with 0.5% sulfur oil, the facility u sed 3600 gallons and the number 2 oil was 0.1865 % Sulfur in the last year. This source is subject to the following rules.

1.40CFR Part 60 Subpart Dc Small Industrial

- Commercial

- Institutional Steam Generating Units 2. Particulate Rule 27.3 3. Opacity Rule 3 10% Opacity limits 6. SO 2 Rule 13.2 Quarterly Sulfur Reports Required5

Memorial Hospital RACT Company Number 2010 Full Compliance Evaluation was completed on December 21, 2006. The source was in compliance. This permit applies to the three 500 hp Johnson boilers that provide steam for Memorial hospital. Natural gas is used to fire the boilers with number 2 fuel oil as a backup fuel in case of natural gas curtailment. By permit condition, only

2boilers can be in operation at a time. Allowable Emissions Particulate 8.20 lb/hr

NO x N/A SO 2 10.15 lb/hr Actual Emissions Particulate 1.235 TPY

NO x 12.57 TPY SO 2 44.46 TPY Available Emission Factors show direct PM2.5 as 0.8820 TPY This source is subject to the following:

40CFR Part 60 Subpart Dc
- Standards of Performance for Small Industrial

- Commercial

- Institutional Steam Generating Units. The NSPS limits the sulfur in the fuel oil to 0.5% Rule 8.2 limits particulate to 8.2 lb/hr Rule 13 limits SO 2 to 300 ppm.6

Rock Tenn Converting Company Company Number 47

- 065

- 3455 Full Compliance Evaluation completed on December 12, 2006. Source was in compliance Allowable Emissions Particulate 23.074 TPY

NO x 96.76 TPY SO 2 349.19 TPY Allowable emissions are based on 2% sulfur content and 3,500,000 gallons per ye ar. Actual oil sulfur content is normally c onsiderably

l ess than 2%. Natural gas is the primary fuel and is used when it is available and is cost competitive. This source is subject to the following; 40 CFR Part 70 Operating Permit Program The following local rules;

1. Particulate Rule 26.6 2. Opacity Rule 3 3. VOC Rule 25.3 4. SO 2 4

- 60(d)(9) Actual emissions from the boilers in the last year are as follows

Particulate 15.25 TPY NO x 73.92 TPY SO 2 174.97 TPY The lower actual emissions occurred because the facility used Number 6 fuel with a sulfur content of 1.61 % for the first 6 months and 0.99% for the second six months of the ye ar. This source is a candidate for contingency measures. Specifically, the oil sulfur limit may be further restricted.7

Signal Mountain Cement Company Number 47

- 065

- 3070 Reconstr ucted 2001 Full Compliance Evaluation by Chattanooga

-Hamilton County APCB November 26, 2006. The source was found to be In Compliance. Full Compliance Evaluation by Region 4 March 13, 2007 the source was found to be In Compliance. Stack Tests NO x Sept 2001 and Jan 2007 Particulate Sept 2001 SO 2 Sept 2001 CO Sept 2001 Opacity Sept 2001 Emissions Particulate 64.18 tons per year

NO x 1651 tons per year SO 2 0 Subject to the following as adopted into the Chattanooga Air Pollution Control Ordinance 1. NO x SIP Call 2. 40 CFR Part 63 Subpart LLL National Emissions Standards for Hazardous Air Pollutants from the Portland Cement Industry 3. 4 0 CFR Part 60 Subpart F Standards of Performance for Portland Cement Plants 4. 40 CFR Part 6 0 Subpart Y Standards of Performance for Coal Preparation Plants 5. 40 CFR Part 64 Compliance Assurance Monitoring 6. 40 CFR Part 70 Operating Permit Program 7. Chattanooga Air Pollution Control Ordinance Rules 2.6, Rule 27, Rule 26, and Rule 18 . COMS on Kiln Baghouse. Observed Opacity between 0 and 5%. Pressure differential recorded as required by the permit. All pressures differentials in compliance Periodic opacity

readings recorded as required by the permit. No reading in violation. NO x monitored using back end oxygen correlation in compliance. Recorded at at least 1 minute intervals.8 Nine Baghouses subject to CAM. One equipped with COMs. Eight require pressure drop readings. Daily qualitive visible observations for all emissions units except for those equipped with COMs are required. If opacity i s greater than 10 % then a daily Method 9 reading is required. If the limit for a particular unit is exceeded, then a Method 9 reading is required daily until the unit is in compliance.9

Archer Daniels Midland Company d/b/a Southern Cellulose Products Company Number 3110 Full Compliance Evaluation was completed on November 1, 2006. Allowable Emissions Particulate 14.51 lb/hr

NO x No NO x limit for small boilers. Heaters NO x

allowabl e 0.56 lb/hr (Process Equipment) SO 2 57.71 lb/hr Actual Emissions Particulate 3.28 TPY

NO x 40.67 TPY SO 2 0.410 TPY This source is subject to the following rules.

1. Particulate Rule 26.6, 4

- 8(e)(2)(b), Rule 10 2. Proce ss NO x Rule 2.4 2. Opacity Rule 3, Rule 26.20 3. SO 2 Rule 1310

Caraustar Mill Group, Inc. d/b/a Chattanooga Paperboard Company Number 47

- 065

- 0700 Full Compliance Evaluation completed on May 3, 2007. The source was in compliance. Allowable Emissions Particulate 11.42 TPY

NO x 30.078 TPY SO 2 245 TPY Allowable emissions are based on 2% sulfur content of fuel oil. Boiler #2 is subject to 40CFR Part 60 Subpart Dc Standard of Performance for Small Industrial

- Commercial

- Institutional S team Generating Units The source is subject to; 40 CFR Part 70 Operating Permit Program This source is subject to the following local rules.

1. Particulate Rule 26.6 2. Opacity Rule 3 3. VOC Rule 25.3 4. SO 2 4

- 57(a)(1) 5. Particulate Rule 2 711

Ergon Terminaling RACT Company Number 4040 Full Compliance Evaluation was completed on July 3, 2007. This permit applies to a terminal storage facility for asphalt cement, caustic soda, and sty rene monomer. On average, 32 barges per year are unloaded per ye ar. There are emissions of VOC from the products but the heaters are the sources of PM 2.5 precursors and direct PM2.5 . The facility operates 4 heaters and boilers. These are the following: Hopkins Thermal Liquid Heater 8.6 million BTU/hr VA Power Boiler 5 million BTU/hr VA Power Thermal Liquid heater 6.6 million BTU/hr Boiler B1 13 million BTU/hr Allowable Emissions Particulate 8.20 lb/hr

NO x N/A SO 2 10.15 lb/hr Actual Emissions Particulate 1.41 TPY

NO x 14.12 TPY SO 2 50.13 TPY Available Emission Factors show direct PM2.5 as 0.8820 TPY Boiler B1 is subject to

40CFR Part 60 Subpart Dc
- Standards of Performance for Small Industrial

- Commercial

- Institutional Steam Generating Units. The NSPS limits the sulfur in the fuel oil to 0.5% Rule 8.2 limits particulate to 8.2 lb/hr12

INVI STA S.à.r.l., LLC Company Number 47

- 065

- 3889 INVI STA, at this time consists of three sources. The sources are INV IS TA, Kordsa, and DuPont. 98.9% of the emissions are from INVISTA. Changes in ownership are such that this permit will soon be broken into three. INVISTA will be the only one of the three that will be a major source. Full Compliance Evaluation completed on May 18, 2006. The source was in compliance.
Emissions Particulate 40.60 tons per year

NO x 273.27 tons per year SO 2 828.44 tons per year Subject to the following as adopted into the Chattanooga Air Pollution Control Ordinance 1. 40 CFR Part 64 Compliance Assurance Monitoring 2. 40 CFR Part 70 Operating Permit Program 3. 4 0 CFR Part 60 Subpart Dc Standards of Performance for Small Industrial

Commercial

- Institutional Steam Generating Units. 4. Chattanooga Air Pollution Control Ordinance 4

- 8(e)(2), Rule 2, Rule 3, Rule 10, Rule 13, Rule 26, and Rule 27. This source is a major source because of combustion emissions. Boilers 1 and 2 Natural Gas Primary

Fuel Fuel oil limited to 1.830,000 gallons per year in boilers with 0.3 % sulfur. Monitored by

recordkeeping Opacity limit 10% Boilers 3, 4, and 5 Bituminous Coal Fuel limited to 112,000 tons per year. Sulfur limited to 1.25 % by weight. Particulate limited by

Rule 26 Baghouse control. Sulfur monitored by

fuel testing. Coal

- fired boilers demonstrated the same emissions as original tests when Method 5 was performed as part of the Site Specific Health Based Compliance Demonstration Vaporizers 1, 2, 3, 4, 5, and 6. Limited to natural gas and Number 2 fuel oil. 10% opacity limit13 Limited to 2,000,000 gallons per year. Fuel oil limited to 0.3% sulfur. Dowtherm Transport System Condensers followed b y demisters Continuous Poly

merization Line II Scrubber control

. Particulate from polyester flake handling Controlled by

9 bag houses and 2 HEPA filters Particulate from hot chest exhausts of Spinning Machines 201,202,203,211,221,231,241, and 251 Controlled by

ESPs. All control systems have required monitoring in the permit to insure that the controls are working as designed.14

Mueller Company Company Number 47

- 065

- 2150 Reconstructed 1999 Full Compliance Evaluation by Chattanooga

-Hamilton County APCB, November 26 2006. The source was found to be In Compliance. Full Compliance Evaluation by Region 4, March 13, 2007. The source was found to be In Compliance.
Emissions Particulate 47.8 tons per year

NO x 17.14 tons per year SO 2 3.6 tons per year Subject to the following as adopted into the Chattanooga Air Pollution Control Ordinance
1. 40 CFR Part 63 Subpart EEEEE National Emissions Standards for Hazardous Air Pollutants from the Iron and Steel Foundrys 5. 40 CFR Part 64 Compliance Assurance Monitoring 6. 40 CFR Part 70 Operating Permit Program 7 40 CFR Part 60 Subpart Cc Standards of Performance for Small Industrial

Commercial

- Institutional Steam Generating Units. 8 Chattanooga Air Pollution Control Ordinance Rules, Rule 27, Rule 26, Rule 3, Rule 2, Rule 10, Rule 13, Rule 2, Rule 18. Pressure differential recorded as required by the permit. All pressures differentials in compliance Bag leak detectors as required by the MACT are in place Periodic opacity

readings recorded as required by the permit. No reading in violation. Eight baghouses are subject to CAM. These require daily pressure drop readings. Four emission points are controlled by a HEPA filter in series with a baghouse. Foundry visible emissions 10 % except for emissions from buildings and then iy t is 5%. Foundry landfill visible emissions limit is 10%.15

Saint

- Gobian Norpro RACT Company Number 2220 Full Compli ance Evaluation completed on December 8, 2006. The source was in compliance Allowable Emissions Particulate 83.5 TPY

NO x 10 TPY SO 2 72 TPY Actual Emissions Particulate 10.2 TPY

NO x 3.5 TPY SO 2 20 TPY This source is sub

ject to the following rules. 1. Particulate Rule 10.3 , Rule 26.3, and 4

- 8(e)(2)(b) 2. Process NO x Rule 2.4 2. Opacity Rule 3 10% Opacity limits 3. Process gaseous emissions Rule 23 4. SO 2 Rule 13.216

Southeastern Materials (Shallowf ord Plant) Company Number 6008 Full Compliance Evaluation was completed on June 23, 2006. The source was in compliance. Allowable Emissions Particulate 71.83 TPY

NO x 24.3 TPY SO 2 6.69 TPY Actual Emissions Particulate 22.1 TPY

NO x 20.5 TPY SO 2 2.25 TPY Available Emission Factors show direct PM2.5 as 2.25 TPY This source is subject to the following :

40CFR Part 60 Subpart I Standards of Performance for Hot Mix Asphalt Facilities The NSPS sets a PM emissions limit of 0.04 gr/dscf and a visible emission limit of less than 20%. The facility

is subject to the following local Rules; 1. Rule 27.1 which requires particulate BACT applies. The NSPS particulate limit is considered as BACT but a 10% opacity limit is required under Rule 27.1 2. Rule 2.4 limits NO x emissions to 300 ppm 3. Rule 13 limits SO 2 to 300 ppm. The stack test required by the NSPS was conducted in August 1999.17